GODDARD, District Judge.
These two actions were tried together without a jury upon stipulation, and were brought to recover, respectively, $1,677,005.79 and $1,672,828.77 income tax assessed against the plaintiffs for the year 1920 by the Commissioner of Internal Revenue, and paid in 1927 after the plaintiffs had appealed to the Board of Tax Appeals and the Board had affirmed the order of the Commissioner. The taxes were paid under protest to the defendant's testator...
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